ML13333B376
| ML13333B376 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/28/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC/EDO |
| References | |
| NUDOCS 8605050034 | |
| Download: ML13333B376 (5) | |
Text
APR 28 81986 MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 (SONGS-1)
INSERVICE TESTING (IST) REVIEW In the enclosure to your February 4, 1986 memorandum to Office Directors, you requested that NRR evaluate whether or not a backlog of license amendments and technical specification changes contributed to delays in approving the San Onofre 1 IST program. NRR has completed this evaluation which is described in detail in Enclosure 1. In summary, NRR has concluded that a backlog of San Onofre 1 license amendments did not directly contribute to delays in approving the San Onofre 1 IST review.
During the 33 month outage when continued operation of SONGS-1 was uncertain, a delay did occur that was caused by the licensee not providing submittals to resolve NRC concerns. However, at other times during the review the NRC staff also contributed to the delay. Due to the workload involved in performing the IST review for all operating plants and the fact that many other issues at operating nuclear plants were of higher safety significance, staff resources were not always available to review certain San Onofre 1 IST submittals until long after they had been received. Additionally, the existing backlog of all other licensing actions in NRR also contributed to this delay. Details of the chronology and current status of the IST program review are provided in.
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
- 1. Evaluation of License Amendments
- 2. Inservice Testing Review Status
Contact:
8605050034 860428 R. Dudley, NRR PDR ADOCK 05000206 49-27218 PDR See previous concurrences.*
Office:
LA/PAD#1 PM/PAD#1 PD/PAD#1 PAEB PAEB AD/DPLA TC for Surname:
PShuttleworth* RDudley*/tg:jm GLear*
GBagchi* RBallard* ERossi*
Date:
04/04/86 04/04/86 04/07/86 04/14/86 04/14/86 04/14/86 Office:
D/DPLA
/NRR D/ R Surname:
TNovak*
DEi enhut HD ton Date:
04/15/86 04/
/'86 04/&86
ENCLOSURE 1 REQUEST:
Evaluate whether a backlog of license amendments and technical specification changes contributed to delays in approving the licensee's IST program.
RESPONSE
As of December 31, 1985, San Onofre 1 had 10 uncompleted license amendment requests, one of which was the review of the licensee's IST program and associated technical specifications. A review of the Regulatory Information Tracking System (RITS) data for other operating plants at this same time indicated that the average number of outstanding license amendments was about 11.5 per plant. None of the other 9 uncompleted amendments were assigned to Mechanical Engineering Branch of the Division of Engineering which was responsible for the IST review prior to the November 24, 1985 reorganization. Since SONGS-1 currently has fewer than the NRC average number of uncompleted license amendments, the staff concludes that a backlog of amendments was not the cause for the delay in the IST review.
The staff also examined past license amendment application data which was compiled by a review of old ORLAS data and NRC Pink Books (NUREG-0328) dating back until 1977. The number of open license amendments at SONGS-1 has never been significantly higher than the current NRC average of 11.5 license amend ments per plant. The peak of 18 open license amendments in June 1984 was due to amendments associated with facility modifications made during the 33-month seismic upgrading outage which ended when SONGS-1 restarted on November 27, 1984. These needed amendments were promptly implemented and the peak of 18 amendments was reduced to 9 as of November 30, 1984.
Thus, based upon the above information the staff concludes that a backlog of license amendments did not delay approval of the licensee's IST program.
17Z 98
_1 he-74 tk a
II a
F/M qj[ -
1M /-
Y fltr~o ly
&~lf 9W-
'4L--
/
A6F-P st--
SH&-A CO ru 4eMI 87 vs.
-- 799--
P' L~lk PDR&~00--
ENCLOSURE 2 INSERVICE TESTING REVIEW STATUS On June 24, 1977, SCE submitted proposed technical specifications for Inservice Inspection and Testing (ISI/IST) requirements for ASME Code Class 1, 2, and 3 components. Additional information regarding ISI and IST was provided on September 28, 1977.
On December 22, 1977, after a preliminary review of the licensee's program, the NRC granted interim approval to the licensee's ISI/IST relief requests and directed SCE to implement their proposed program on January 1, 1978.
Further additional information was provided on May 26, 1978, and September 4, 1979, and in meetings on June 26 and 27, 1978. Amendment 46, dated September 26, 1979, implemented the ISI Technical Specifications and approved certain relief requests from ASME Code requirements.
By letter dated April 30, 1980, the NRC modified several of the relief requests contained in Amendment 46.
The IST Program was reviewed independently from the ISI Program, with the licensee providing additional information on September 11, 1979. SONGS 1 was shut down on February 27, 1982. Due to seismic design concerns, the licensee was not specific with regard to returning the facility to service. No further NRC/SCE correspondence was generated until January 26, 1983 when additional IST questions were telecopied to the licensee in preparation for a meeting held at the site on February 2, 3, and 4, 1983. Additional requests for information were generated during this meeting but were not responded to by the licensee since facility restart was uncertain. On December 12, 1983, SCE submitted the SONGS 1 Return-to-Service Program to the NRC. On January 24, 1984, SCE responded to staff questions raised during the February 1983 meeting by submitting a complete revision of the IST Program. This program was further revised by SCE submittals dated June 15, 1984, September 11, 1984, and April 10, 1985. The staff review of the licensee's program has found that the five failed check valves were included in the licensee's testing program and were tested in accordance with ASME Code Section XI requirements. However,Section XI requirements are not always sufficient to detect the type of progressive degradation that occurred in these check valves prior to their failure.
On March 3, 1986 the licensee submi.tted a revised IST program which superseded the program that has been reviewed by the staff. The staff is now evaluating the differences between the previous and current programs to determine if our initial evaluation is still applicable to the March 3, 1986 program.
On April 8, 1986, the licensee submitted a Restart Report which is intended to address all NRC concerns related to the November 21, 1985 event. In this document, the licensee committed to disassemble at least one of each set of new feedwater check valves and inspect them for indications of degradation at the next refueling outage. Based on the results of these inspections, a determination will be made regarding future inspections. The staff review of these related issues is ongoing and will be completed for the feedwater system check valves prior to facility restart.
APR 28 1986 Central Files NRC PDR Local PDR EDO Reading PAD#1 r/f T. Rehm G. Bagchi R. Ballard E. Rossi G. Lainas D. Crutchfield Denton/D. Eisenhut G. Lear T. Novak J. Heltemes, AEOD R. Dudley P. Shuttleworth